Summary
The United States District Court for the District of Maine adopts and affirms a magistrate judge’s recommendation to dismiss Seth Carey’s complaint against the Maine State Police, the Rumford Police Department, prosecutors, and individual officers. The court concludes that the Rooker-Feldman doctrine bars challenges to the state protection-from-abuse proceeding and that the claims also fail on sovereign immunity, prosecutorial immunity, municipal liability, pleading, and injunctive-relief grounds. The court overrules Carey’s objections and dismisses the complaint.
Topics
Practice areas
Questions Presented
- Whether the Rooker-Feldman doctrine barred Carey's federal challenge to the state-court protection-from-abuse order.
- Whether the Maine State Police was immune from suit under the Eleventh Amendment.
- Whether prosecutorial immunity barred the claim against the district attorney in his professional capacity.
- Whether the complaint adequately alleged municipal liability under 42 U.S.C. § 1983 against the City of Rumford based on allegations concerning the Rumford Police Department.
- Whether the complaint adequately alleged specific unconstitutional conduct by the individual defendants and otherwise satisfied the plausibility pleading standard.
- Whether Carey was entitled to injunctive relief concerning state proceedings or enforcement of criminal laws.
Holdings
- The Rooker-Feldman doctrine barred Carey's challenge to the state-court protection-from-abuse order because the state proceeding had been litigated and upheld on appeal.
- The Maine State Police, as a Maine state agency, was immune from suit in federal court under the Eleventh Amendment absent waiver.
- Prosecutorial immunity barred Carey's claim against Robert Granger in his professional capacity as a district attorney.
- The complaint failed to state a Section 1983 claim against the Rumford Police Department, construed as a claim against the City of Rumford, because it did not allege facts establishing that a municipal policy or custom caused a constitutional violation.
- The complaint failed to state a plausible claim for relief because it did not allege specific conduct by the individual defendants connecting them to a violation of Carey's federal or constitutional rights and instead relied on conclusory and speculative assertions.
- Carey was not entitled to injunctive relief because the facts alleged provided no legal basis for federal intervention in the state's management of its affairs.
Key quotations
“there is no justification for invading the State’s latitude to manage its affairs” (ECF No. 6 at 5)
“Although Carey alleges many facts, he does not connect them to the named defendants and instead seeks to relitigate a PFA proceeding that is unreviewable in this Court under the Rooker-Feldman doctrine.” (ECF No. 6 at 6)
Factual background
Carey's claims arose from a state-court protection-from-abuse proceeding and accompanying investigation, which he alleged involved false statements, defamation, and malicious prosecution. He alleged that the proceeding resulted in violations of his constitutional rights, damage to his reputation, and loss of his law license. The state-court PFA decision was litigated and upheld on appeal.
Procedural history
Carey filed a federal complaint asserting constitutional claims under the Fourth, Fifth, and Fourteenth Amendments and state-law claims arising primarily from a state protection-from-abuse proceeding, related investigation, and the loss of his law license. On November 7, 2025, the magistrate judge recommended dismissal on Rooker-Feldman, sovereign-immunity, prosecutorial-immunity, municipal-liability, pleading, and injunctive-relief grounds. Carey objected, but the district court found that his objection identified no specific legal error and adopted and affirmed the recommendation in its entirety.